Employers that sponsor group health plan programs continue to navigate the voluminous requirements imposed under the Affordable Care Act. Top priorities include self-assessment of compliance efforts to date since the enactment of the ACA in 2010 and establishment of a compliance project plan going forward.

Prudent, ongoing recordkeeping and proper plan documentation, reporting and disclosure as required under the ACA must be addressed. Continued efforts must be made to stay abreast of the requirements and due dates for compliance with each requirement under the ACA. Companies weighing the pros and cons of offering compliant health programs to their employees should also assess the importance of such benefits as a tool to attract and retain employees.

Employers that sponsor group health plan programs must ensure that they have individuals administering the plans with the requisite knowledge and expertise. Consideration should be given to designating individuals to serve as the health plan fiduciaries, who may be separate and distinct from the individuals making the business decisions with respect to the health plan program. It may also be important to engage outside service providers to assist in compliance efforts.